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Following up on previous proposals we wrote about earlier this year, today the Securities and Exchange Commission proposed amendments to Form PF, the confidential reporting form for certain SEC-registered investment advisers to private funds, to:

  • Enhance reporting by large hedge fund advisers on qualifying hedge funds;

  • Enhance reporting concerning hedge funds;

  • Enhance reporting on basic information about advisers and the private funds they advise;

  • Amend how advisers report complex structures; and

  • Remove aggregate reporting for large hedge fund advisers.

The SEC's factsheet provides a great overview of the proposed changes, and the team here at PINE will be spending some time reviewing the details of the  proposed rules and what they could mean for our clients.

In a statement released along with the proposed rules, SEC Chairman Gensler said, "I am pleased to support the proposal because, if adopted, it would improve the quality of the information we receive from all Form PF filers, with a particular focus on large hedge fund advisers."

However, the rules in their current form are not without dissenters within the Commission. In a separate statement, Commissioner Peirce said, "Although I have called for changes to Form PF, neither the changes we are considering today, nor the ones we proposed on January 26th, are what I had in mindWhy we need the new information and what we plan to do with it are questions left to the reader’s imagination. Accordingly, I am unable to support the proposal."

Clearly these proposed rules will continue to be the subject of much debate between industry stakeholders, balancing the SEC's desire to boost transparency and reduce systemic risk with a Private Fund's desire to be just that - Private. There will be a 60-day comment period once the proposal is published in the Federal Register, and we will be following those comments and the rule making process through to a potential final rule adoption.

We'd love to hear what you think of the proposed rules and discuss what they could mean for your business. Feel free to reach out to your regular PINE contact or send an email to

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